Los Angeles County Department of Children & Family Services v. S. B.

I would reverse the disqualification orders in their entirety. The evidence in this matter was that in the case of In re Charlisse C. (2007) 149 Cal.App.4th 1554 [ 58 Cal.Rptr.3d 173 ], review granted July 18, 2007, S152822. Evidence developed during the Charlisse C. hearings demonstrated that the Children’s Law Center of Los Angeles (the center), which was originally organized as three separate law firms, had failed to maintain the ethical walls in existence when its structure was approved by Division Three of this appellate district in Castro v. Los Angeles County Bd. of Supervisors (1991) 232 Cal.App.3d 1432, 1435-1445 [ 284 Cal.Rptr. 154 ]. During the proceedings in Charlisse C, in response to the extensive evidentiary showing of noncompliance with Castro , the juvenile court gave a tentative ruling that covers seven pages in the reporter’s transcript and discusses both violations of substance and appearance. *1274 Charlisse C. is a successive representation case where the center had previously represented the mother. (See Flatt v. Superior Court (1994) 9 Cal.4th 275, 282-284 [ 36 Cal.Rptr.2d 537 , 885 P.2d 950 ]; People v. Baylis (2006) 139 Cal.App.4th 1054, 1064-1065 [ 43…

*1257 Opinion

INTRODUCTION

This is one of a number of recent appeals brought by the Children’s Law Center of Los Angeles (the Center or CLC), all from orders of the juvenile court disqualifying the Center from representing children in dependency proceedings because of purported conflicts of interest. 1 The Center created separate units—referred to as CLC Unit 1, CLC Unit 2 and CLC Unit 3—to provide, in the same proceeding, legal representation to multiple clients who might have conflicts of interest. 2 In In re Jasmine S. (2007) 153 Cal.App.4th 835 (Jasmine), we reversed the juvenile court’s orders disqualifying the Center in a case involving the concurrent representation of two clients with potentially adverse interests who were represented by two different units of the Center because there was not an actual conflict of interest.

This case involves the concurrent representation by two of the Center’s independent units of five siblings. In the published portion of this opinion, we affirm the juvenile court’s order disqualifying CLC Unit 1 from representing four of the siblings because the record contains substantial evidence of an actual conflict among those four…